{"id":"8ff1abf0-f18d-44a2-aa49-335d7a72bcfd","test":"OFAC 50 percent rule","value":"Designated itself, so blocked","current":false,"observedAt":"2026-09-17T11:34:44.978Z","confirmedAt":"2026-09-17T11:34:44.978Z","supersededAt":"2026-09-18T11:34:57.277Z","company":{"id":"cf0548b8-17ef-40a9-8798-e7f9cf9806d3","name":"SIA FALCON INTERNATIONAL GROUP"},"previous":{"id":"4cbf38eb-e198-4250-b41c-4a469f3a4ba2","value":"Designated itself, so blocked","observedAt":"2026-09-16T14:44:45.642Z","supersededAt":"2026-09-17T11:34:44.978Z"},"next":{"id":"ec1fdd75-1779-47d7-8070-0846257e3b80","value":"Designated itself, so blocked","observedAt":"2026-09-18T11:34:57.277Z","supersededAt":"2026-09-27T11:34:29.824Z"},"derivation":{"kind":"ownership_verdict","path":[],"test":"OFAC 50 percent rule","notes":["Natural-person holders are compared with designated persons by name only. A match is reported and never counted, because the registers publish no identifier that could confirm it."],"breaks":{"first":[],"total":0,"byReason":{}},"effect":"blocked","inputs":{"lists":[{"readAt":"2026-09-13T14:47:39.470Z","source":"OFAC SDN","publishedAt":"2026-09-10T00:00:00.000Z","publishedAtBasis":"stated_in_file"}],"registers":[{"readAt":"2026-09-14T21:54:42.782Z","source":"Latvia Enterprise Register (members)","publishedAt":"2026-09-14T20:25:33.000Z","holdingsReadAt":{"latest":"2026-09-14T21:53:47.938Z","earliest":"2026-09-14T21:53:47.938Z"},"publishedAtBasis":"server_last_modified"}]},"caveats":["The rule speaks only to ownership. An entity controlled by a blocked person without being owned 50% or more is not blocked by it, though it may be designated in its own right.","1 holder shares a name with a designated party. A name alone is not counted. The birth date the register publishes agrees with the designated person's for that holder (to the month). A birth date is not counted either."],"outcome":"designated","subject":{"number":"45403041088","entityId":"cf0548b8-17ef-40a9-8798-e7f9cf9806d3","countryId":"LV","entityName":"SIA FALCON INTERNATIONAL GROUP"},"holdings":{"total":1,"heldByCompanies":0,"notPublishedAsCompanies":1},"identity":"bef763122cef84798f8af66511235066c9f3acd1a731e52d6125a3b0cfccb9f3","citations":[{"url":"https://ofac.treasury.gov/faqs/topic/1521","title":"OFAC, Frequently Asked Questions: Entities Owned by Blocked Persons (50% Rule)","where":"FAQ 398 (ownership, not control), FAQ 399 (50 percent or more in the aggregate; two blocked persons at 25% each block the entity), FAQ 401 (indirect ownership: an entity 50% owned by a blocked entity is blocked and its holdings count in full)"}],"ruleTable":{"fingerprint":"ec7b82da98b4465749dfa0023ce7812d6c965f69d72df13ea7a20870d93698b0","signedOffOn":"2026-09-17","textsReadOn":"2026-09-13"},"statement":"The company is itself listed under this regime, and blocked as a listed party rather than through its owners.","threshold":"50% or more","computedAt":"2026-09-17T11:34:44.978Z","aggregation":"aggregated","chainComplete":true,"jointHoldings":"not_settled","listedParties":[{"hops":0,"company":{"name":"SIA FALCON INTERNATIONAL GROUP","number":"45403041088","countryId":"LV"},"listings":[{"kind":"asset_freeze","test":"OFAC 50 percent rule","regime":"OFAC","status":"rule_verified","program":"DPRK","entityId":"cf0548b8-17ef-40a9-8798-e7f9cf9806d3","entityName":"SIA FALCON INTERNATIONAL GROUP","sourceName":"OFAC SDN","designatedAt":null}]}],"controlAssessed":false,"designatedShare":{"sole":100,"includingJoint":100},"nearestDesignated":"The company is itself designated.","nameOnlyCandidates":1,"restsOnJointHolding":false,"naturalPersonHoldings":{"count":1,"masked":0,"directShareOfSubject":100}}}